Herman v. Crossfield
REITERATIONFacts
The Antecedents: On March 8, 1906, a final judgment was entered in the Court of First Instance of Manila in favor of Meyer Herman (defendant) in an action where Rubert and Guamis were plaintiffs. Procedural History: On March 14, 1906, the plaintiffs moved for a new trial, alleging the findings were against the weight of evidence. No order was made on this motion. On March 26, 1906, the plaintiffs filed another motion to set aside the decision and reopen the case to present the testimony of Dr. Altman. This motion was heard on March 31, 1906, the last day of the term. The court decided this motion on April 14, 1906, after the term had expired, ordering the case reopened for Dr. Altman's testimony, noting there was no showing of newly discovered evidence. The Petition: On July 12, 1906, Meyer Herman commenced an original action of certiorari in the Supreme Court, asserting that the April 14, 1906 order was void due to the court's lack of jurisdiction after the term had expired.
Issue(s)
Whether the Court of First Instance had jurisdiction to entertain and decide a motion for a new trial after the expiration of the term at which the judgment was entered. Whether the order reopening the case for the testimony of Dr. Altman was valid.
Ruling
The demurrer to the complaint is sustained, and the plaintiff is allowed ten days to amend his complaint. If no amended complaint is filed, final judgment will be entered in favor of the defendants.
Ratio Decidendi
On the issue of jurisdiction to decide a motion for a new trial after the term has expired: The Court held that the contention that the court was without jurisdiction to entertain or decide a motion for a new trial after the expiration of the term cannot be sustained. This is in view of prior decisions of the Supreme Court, specifically citing Santos vs. Villafuerte. These cases established that the Court of First Instance possesses the jurisdiction to entertain and decide a motion for a new trial even after the term in which the decision was rendered has closed. The ruling in those cited cases directly disposes of the present case's primary contention regarding jurisdiction. Therefore, the court below retained jurisdiction to act upon the motion filed by the plaintiffs. On the validity of the order reopening the case: The Court stated that whether the order made on April 14 was correct or incorrect was not before them for decision. The crucial point was that the court had jurisdiction to decide the motion, irrespective of whether it was correctly decided. If the decision on the motion was erroneous, the remedy for the defendant (petitioner in the certiorari case) was to except to the order. While this order was not a final judgment allowing an immediate appeal, the defendant could raise the issue for review after a final judgment was entered in the main case. Thus, the validity of the reopening order itself, as opposed to the court's jurisdiction to issue it, was a matter for appeal, not certiorari.
Main Doctrine
A Court of First Instance has jurisdiction to entertain and decide a motion for a new trial even after the term at which the judgment was rendered has expired.